DATE LAST MODIFIED: August 13, 2020
Importance of Your Privacy
A Special Note about Children
Children are not eligible to use our Services and we ask that minors (under the age of 16) do not submit any personal information to us or use the Services. Upstream does not collect or maintain information from those actually known to be under the age of 16, and not part of Upstream’s website, software, or services is structured to attract anyone under the age of 16.
Important Categories of Information for you to Know:
• Who we are
• Information we may collect
• How your information is used
• Where we process data
• Legal basis for data collection
• Altering the information you submit to us
Who we are
Upstream Growth Consultants LLC. provides personal and professional consulting and training to individuals and organizations using a cognitive behavioral based process and curriculum.
Information We Collect
There are several areas where you may be asked for both personal and non-personal information. We DO NOT sell or share any personal information about you to or with any person or organization except (i) as authorized by you, (ii) as described in the relevant portion of Upstream’s Website, (iii) in connection with providing various services to you, (iv) as may be required by law or court order, or (v) as otherwise set forth herein. In particular, and not in limitation of the foregoing, information you provide to Upstream will be shared with the vendors which Upstream has entered into a business relationship in order to complete services.
Information we receive from you. To use certain parts of Upstream’s services, you’ll need to provide certain personal information which may include, without limitation, your name, company name, phone number, credit card information, and/or e-mail address, as well as other information.
Technical information we collect. In order for Upstream to ensure that we are providing the best possible consumer experience, we collect and track certain user information. When you visit our website, our Web server sends a cookie to your computer. This cookie stores a limited amount of information about your site visit. The cookie tracks aggregate information on how our site is being used, including session counts, navigation patterns, pages visited, etc. These cookies, however, do not store any personally identifiable information such as your name, email address or phone number as you browse the site. Upstream may also utilize Web logs to track aggregate information about how our site is being used. Web logs track anonymous user information, including the number of visitors to the website, IP addresses(if publicly available), and browser type. Unlike cookies, Web Logs are maintained only on Upstream's servers and do not store or place anything on a user’s computer. If you come to Upstream’s website from an online banner ad, an anonymous identification number may be passed to the website. This information cannot be used to gather any personally identifiable information about you. It will only allow us to track the overall effectiveness of our online advertising, marketing, and banner advertisement campaigns.
Information from Surveys. You may have the option of completing an online survey from Upstream. Participation in surveys are completely voluntary and it is your choice whether or not you wish to disclose your personal information to us in connection with any such survey.
Information from the “Contact Us” section of the website. You may contact Upstream through the “Contact Us” feature. Participation in this area is completely voluntary and it is your choice whether or not you wish to disclose your personal information to us.
Our website uses Google Analytics, which is a web analytics service provided by Google, Inc. (“Google”), to evaluate your use of the website. Google Analytics places a third-party cookie on your computer that is then use to compile reports of individual profiles for each visitor and only collects aggregate data.
For information on how Google Analytics uses data please visit “How Google uses data when you use our partners’ sites or apps”, located at https://policies.google.com/technologies/partner-sites.
How your information is used
We use the information you provide to provide the applicable Services to you. Upstream does not share your information with other third parties for marketing or demographic purposes. In order for us to provide these Services to you, it may be necessary for us to share your personal information with additional third parties for processing. These parties are not allowed to use personally identifiable information except for the purpose of providing these Services. If you do not want your data to be shared, you can choose not to allow the transfer by not using that particular Service. In addition, Upstream may disclose account or other personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury or interference with Upstream’s rights or property, other Website or anyone else that could be harmed by such activities.
Upstream may be forced to disclosed an individual’s personal information when compelled by a lawful request made by a recognized public authority or where required to meet national security and or law enforcement requirements. Upstream is subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”).
In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Upstream is potentially liable.
Where we process data
If you choose to provide Upstream with information, including personal data from our website or applications, you understand that we are storing and/or transferring it to Upstream Systems within the United States.
If you choose to provide Upstream with information, including personal data for services Upstream is to provide, you understand that we are storing and/or processing it only from within Upstream’s server facilities located in the United States.
Altering information you submit
Upstream understands that the right of access is fundamental to privacy protection. Accordingly, individuals may: (a) obtain from Upstream confirmation of whether or not it processes their Personal Data, (b) cooperate with Upstream to determine the accuracy and lawfulness of Upstream’s processing of Personal Data, and (c) have the data corrected, amended or deleted where it is inaccurate, but only to the extent practicable. Inquiries about access should be directed to email@example.com.
Delete your information. Federal and state regulation may require that we store questions or submissions for various periods of time. In order to comply with these regulations, we may be unable to delete information from our databases.
Choice – Timing of Opt-Out. Due to the nature of the services it provides to its clients, it is difficult for Upstream to provide individuals the option to opt-out. Upstream therefore encourages individuals to first request to opt-out with their employer. In support of the opt-out concept and Upstream’s commitment to the principle of choice, individuals who desire to exclude their Personal Data from the processing Upstream performs, they may send a request to firstname.lastname@example.org . Upstream will forward such requests to your employer and together they will determine the best course of action.
For EU Citizens
Data is collected for Services directly from EU citizens only after explicit opt-in consent is given by the individual
Data that is submitted by a third party (typically the employer) on behalf of an individual is collected only out of the necessity for the performance of the contract with the employer to which the data subject is a party.
EU Citizens have the right of access and correction of their personal data.
EU citizens have the right to request erasure of their data. For data used in the processing of services some data may need to be retained for reasons stated in Article 17; Paragraph 3 of the GDPR
Upstream uses extensive and sophisticated secure technology to protect your data and transmissions between you and Upstream. Transmission between browsers and our web server is implemented using Secure Socket Layer (SSL) technology. This technology requires an SSL-capable browser. Our databases are physically separated from our web server and is protected by a physical firewall. Although Upstream has taken these reasonable and appropriate measures to ensure that your personal information is delivered and disclosed only in accordance with your instructions, Upstream cannot and does not guarantee that the personal information you provide will not be intercepted by others and decrypted.
By e-mail: email@example.com
We may, in the future, sell or otherwise transfer some or all of our assets or equity to a third party. Your personally identifiable information and other information we obtain from you may be disclosed to any potential or actual third party purchasers of such assets or equity and may be among the assets transferred.